IR 05000250/2004007: Difference between revisions

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{{Adams
{{Adams
| number = ML033250512
| number = ML050380365
| issue date = 11/20/2003
| issue date = 02/17/2004
| title = Notification of Triennial Fire Protection Baseline Inspection Report Nos. IR 05000250-04-007 and IR 05000251-04-007 to Be Conducted in January and February 2004
| title = IR 05000250-04-007, 05000251-04-007, on 01/26-30/04 and 02/09-13/04, Inspection Summary - Triennial Fire Protection Inspection at Turkey Point Nuclear Plant
| author name = Ogle C
| author name = Fillion P, Payne D, Wiseman G
| author affiliation = NRC/RGN-II/DRS/EB
| author affiliation = NRC/RGN-II/DRS
| addressee name = Stall J
| addressee name =  
| addressee affiliation = Florida Power & Light Co
| addressee affiliation =  
| docket = 05000250, 05000251
| docket = 05000250, 05000251
| license number = DPR-031, DPR-041
| license number = DPR-031
| contact person =  
| contact person =  
| case reference number = IR-04-007
| case reference number = FOIA/PA-2004-0277
| document type = Inspection Report Correspondence, Letter
| document report number = IR-04-007
| page count = 7
| document type = Inspection Report
| page count = 3
}}
}}


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=Text=
=Text=
{{#Wiki_filter:ber 20, 2003
{{#Wiki_filter:February 17, 2004 INSPECTION SUMMARY - TRIENNIAL FIRE PROTECTION INSPECTION AT TURKEY POINT NUCLEAR PLANT Report Number: 50-250, 251/2004007 Onsite Inspection Dates: 1/26-30/04 and 2/9-13/04 Inspection Team: Charlie Payne (team lead, operations); Gerry Wiseman (fire protection); Paul Fillion (electrical)
Accompanying Personnel: Kathleen O'Donohue, Team Leader; Necota Staples (electrical-training); Esperanza Espana, Visiting Inspector (Spain)
Scope: Routine Triennial Fire Protection Inspection, per IP 71111.05, focusing on selected fire areas/zones listed below. Selected fire areas included: Fire Zone 63 (Fire Area T) - Unit 3 Rod Control Equipment/3B MCC Room, +18 f level. Fire barriers in this area consist of 3-hour rated fire walls, the floor and the ceilin Fire detection includes ionization smoke detectors. Manual suppression is provided by the fire brigade. A severe fire in this area would involve a shutdown of Unit 3 from the main control room. Fire Zone 67 (Fire Area U) - Unit 4 Train B 4160V Switchgear Room, +18 ft. leve Fire barriers in this area consist of 3-hour rated fire walls, the floor and the ceiling. Fire detection includes ionization smoke detectors. Manual suppression is provided by the fire brigade. A severe fire in this area would involve a shutdown of Unit 4 from the main control room. Fire Zones 106 and 106R (Fire Area MM) - Unit 3 and Unit 4 Main Control Room, +42 ft. level. Fire barriers in this area consist of 3-hour rated fire walls, the floor and the ceiling. Fire detection includes ionization smoke detectors. This is a normally occupied space with manual suppression initially provided by the control room operators and later by the fire brigade. A severe fire in this area would involve a shutdown of both Unit 3 and Unit 4 from the main control room.


==SUBJECT:==
There were six inspection findings and five other issues identified.
NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION REPORT NO. 05000250/2004007, 05000251/2004007)


==Dear Mr. Stall:==
FINDINGS 1) Failure to periodically test the auto start feature (on loss of power) for the TD fire pump.
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
Region II staff will conduct a triennial fire protection baseline inspection of Units 3 and 4 at the Turkey Point Nuclear Plant in January and February 2004. The inspection team will be led by Mr. Charles Payne, Senior Reactor Inspector, of the Region II Office. The team will be composed of personnel from the NRC Region II Office. The inspection will be conducted in accordance with the NRCs baseline fire protection inspection procedure 71111.05.


The inspection objective will be to evaluate your fire protection program implementation with emphasis on post-fire safe shutdown capability and the fire protection features provided to ensure at least one post-fire safe shutdown success path is maintained free of fire damage.
2) Height of the curbs for some oil-retention basins are not sufficient to contain the entire contents of storage tanks.


The inspection team will focus their review on the separation of the systems and equipment necessary to achieve and maintain safe shutdown and fire protection features of selected fire areas.
3) Failure to identify that the RWST suction valve (LCV-3/4-11 5B) was subject to spurious operation. Applies to both FZ 63 and FZ 6 ) Failure to prevent spurious operation of thermal barrier cooling suction valve (MOV-4-626). Applies to FZ 67. (Licensee identified, but failed to take timely corrective action)
5) Failure to maintain adequate fire detector capability to ensure fire detection at the incipient stage. Applies to FZ 6 ) Local manual operator action to prevent spurious operation of a thermal barrier cooling water containment isolation valve (MOV-3/4-71 6A) was not timely to preclude RCP seal package damage. Applies to FZ 106.


On November 18, 2003, during a telephone conversation with Mr. Walt Parker, Licensing Manager, our respective staffs confirmed arrangements for a three-day information gathering onsite visit and a two-week onsite inspection. The schedule for the inspection is as follows:
7) Failure to install detection and fixed suppression in FZ 97. Part of the MCR envelop OTHER ISSUES 1) Assured operator access through security doors to various rooms and compartments during performance of local manual operator actions.
 Information gathering onsite visit - January 7-9, 2004
 Week 1 of onsite inspection - January 26-30, 2004
 Week 2 of onsite inspection - February 9-13, 2004 The purposes of the information gathering visit are to obtain information and documentation needed to support the inspection, and to become familiar with the Turkey Point Nuclear Plant fire protection program, fire protection features, post-fire safe shutdown capabilities and plant layout. The types of documents the team will be interested in reviewing, and possibly obtaining, are listed in the Enclosure. Please contact Mr. Payne prior to preparing copies of the materials listed in the Enclosure. The inspection team will try to minimize your administrative burden by specifically identifying those documents required for inspection preparation.


During the information gathering visit, the team will also discuss the following inspection support administrative details - office space, specific documents to be made available to the team in its office space, arrangements for reactor site access (including radiation protection training,
2) Assured operator access through specific locked security doors (no key card access available) during MCR evacuation local manual operator actions.


FPL    2 security, safety and fitness for duty requirements), and the availability of knowledgeable plant engineering and licensing organization personnel to serve as points of contact during the inspection.
3) Unapproved local manual operator actions that were found to be feasible. (Licensee identified)
4) Procedure guidance allowing 20 minutes to complete local manual operator actions to restore RCP seal package cooling rather than 13 minutes as specified for similar condition during SBO events. (Licensee identified, but failed to take timely corrective action)
Inspection Successes:
1) Continue to experience a good synergistic working relationship between inspectors.


We request that during the inspection weeks you ensure that copies of analyses, evaluations or documentation regarding the implementation and maintenance of the Turkey Point Nuclear Plant fire protection program, including post-fire safe shutdown capability, be readily accessible to the team for its review. Of specific interest are those documents which establish that your fire protection program satisfies NRC regulatory requirements and conforms to applicable NRC and industry fire protection guidance. Also, personnel should be available at the site during the inspection who are knowledgeable regarding those plant systems required to achieve and maintain safe shutdown conditions from inside and outside the control room (including the electrical aspects of the relevant post-fire safe shutdown analyses), reactor plant fire protection systems and features, and the Turkey Point fire protection program and its implementation.
2) Developed new line of inquiry regarding operator access controls during fires.


Your cooperation and support during this inspection will be appreciated. If you have questions concerning this inspection, or the inspection teams information or logistical needs, please contact Mr. Payne at (404) 562-4669, or me at (404) 562-4605.
Inspection Challenges:
1) Understanding the licensing basis in fire protection still continues to be problemati Licensee is arguing that the are only committed to select sections of NFPA codes but have no record as to which sections they are.


Sincerely,
2) Scope of inspection is greater than inspection resources. Reducing sample size (included in new revision to IP 71111.05) will assure thorough review of area(s) selected.
/RA/
Charles R. Ogle, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos.: 50-250, 50-251 License Nos.: DPR-31, DPR-41 Enclosure: Triennial Fire Protection Inspection Support Documentation cc w/encl:
T. O. Jones Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company Electronic Mail Distribution Walter Parker Licensing Manager Turkey Point Nuclear Plant Florida Power and Light Company Electronic Mail Distribution (cc w/ encl contd - See page 3)


FPL  3 (cc w/encl contd)
3) The licensee is committed to using the EOPs as overall operating guidance during response to fire. Fire response procedures are lower tier documents (off-normal procedures) used as guidance only. Where conflicts between these procedures occur, the EOPs would have priority - despite the need to take some actions to protect safe
Michael O. Pearce Plant General Manager Turkey Point Nuclear Plant Florida Power and Light Company Electronic Mail Distribution Don Mothena, Manager Nuclear Plant Support Services Florida Power & Light Company Electronic Mail Distribution Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power & Light Company Electronic Mail Distribution M. S. Ross, Attorney Florida Power & Light Company Electronic Mail Distribution Linda Tudor Document Control Supervisor Florida Power & Light Company Electronic Mail Distribution Attorney General Department of Legal Affairs The Capitol Tallahassee, FL 32304 William A. Passetti Bureau of Radiation Control Department of Health Electronic Mail Distribution County Manager Metropolitan Dade County Electronic Mail Distribution Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs Electronic Mail Distribution (cc w/encl contd - See page 4)


FPL    4 (cc w/encl contd)
; .
Curtis Ivy City Manager of Homestead Electronic Mail Distribution Distribution w/encl:
shutdown at the cost of reducing normal redundancy and reliability of ECCS equipmen This leaves the licensee vulnerable to actions contrary to SSD analysis and places high reliance on operator training and decision-making. The team found no basis to refute the licensee's approach but noted it was contrary to nearly all the rest of the industr ) The licensee's Ignition Source Data Sheets (ISDS) from the IPEEE contain skimpy information and are not adequate to support an SDP analysis in the fire protection are The licensee's risk analyst was aware of this and stated improvement plans would be implemented, within budget constraint Suggested areas of routine inspection focus:
E. Brown, NRR L. Slack, RII EICS RIDSNRRDIPMLIPB PUBLIC OFFICE RII:DRS RII:DRP RII:DRS RII:DRS SIGNATURE RA RA RA RA NAME PAYNE MUNDAY OGLE ODONOHUE DATE  11/18/2003 11/20/2003 11/20/2003 11/20/2003 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO PUBLIC DOCUMENT YES NO OFFICIAL RECORD COPY DOCUMENT NAME: C:\ORPCheckout\FileNET\ML033250512.wpd
Consider effects of room and compartment access controls when evaluating an operator's ability to successfully perform local manual operator action  
 
Triennial Fire Protection Inspection Support Documentation Note: This is a broad list of the documents the NRC inspection team may be interested in reviewing, and possibly obtaining, during the information gathering site visit. The current version of these documents is expected unless specified otherwise. Electronic media is the preferred if readily available. (The preferred file format is searchable .pdf files on CDROM. The CDROM should be indexed and hyperlinked to facilitate ease of use.
 
Please provide 5 copies of each CDROM submitted.) Information in lists should contain enough information to be easily understood by someone who has a knowledge of the technology. The lead inspector will discuss specific information needs with the licensee staff and may request additional documents.
 
1. The Fire Protection Program document and the Fire Hazards Analysis.
 
2. The fire protection program implementing procedures (e.g., administrative controls, surveillance testing, fire brigade).
 
3. The fire brigade training program document and the pre-fire plans for the selected fire zones/areas (to be determined during information gathering visit).
 
4. The post-fire safe shutdown analysis, including system and separation analyses.
 
5. The alternative shutdown analysis.
 
6. Piping and instrumentation (flow) diagrams for the fire suppression systems.
 
7. Piping and instrumentation (flow) diagrams for the systems and components used to achieve and maintain hot standby, and cold shutdown, for fires outside the control room.
 
8. Piping and instrumentation (flow) diagrams for the systems and components used to achieve and maintain hot standby, and cold shutdown, in areas requiring alternative shutdown capability.
 
9. Plant layout and equipment drawings which identify the physical plant locations of hot standby and cold shutdown equipment.
 
10. Plant layout drawings which identify plant fire area and/or fire zone delineation, areas protected by automatic fire suppression and detection, and the locations of fire protection equipment for the selected fire zones/areas (to be determined during information gathering visit).
 
11. Plant layout drawings which identify the general location of the post-fire emergency lighting units.
 
12. Plant operating procedures used to, and describing, shutdown from inside the control room with a postulated fire occurring in any plant area outside the control room.
 
Enclosure
 
13. Plant operating procedures used to implement the alternative shutdown capability from outside the control room with a fire in either the control or cable spreading room (or any other alternative shutdown area).
 
14. Maintenance and surveillance testing procedures for alternative shutdown capability (including Appendix R emergency lights and communication systems) and fire barriers, detectors, fire pumps and fire suppression systems.
 
15. Calculations and/or justifications that verify fuse/breaker coordination for the selected fire zones/areas (to be determined during information gathering visit) that are fed off the same electrical buses as components in the protected train. Also, a list of the maintenance procedures used to routinely verify fuse/breaker coordination in accordance with the post-fire safe shutdown coordination analysis.
 
16. A list of the significant fire protection and post-fire safe shutdown design change descriptions (including their associated 10 CFR 50.59 evaluations) and Generic Letter (GL) 86-10 evaluations.
 
17. A list of the protection methodologies (as identified in 10 CFR Part 50, Appendix R, Section III.G) used to achieve regulatory compliance for the selected fire zones/areas (to be determined during information gathering visit). That is, please specify whether 3-hour rated fire barriers (Section III.G.2.a), 20-foot separation along with detection and suppression (Section III.G.2.b), 1-hour rated fire barriers with detection and suppression (Section III.G.2.c), or alternative shutdown capability (Section III.G.3) is used for the selected fire zones/areas.
 
18. Procedures or instructions that govern the implementation of plant modifications, temporary modifications, maintenance, and special operations, and their impact on fire protection.
 
19. Organization chart(s) of site personnel down to the level of the fire protection staff.
 
20. Procedures or instructions that control the configuration of the fire protection program, features, and post-fire safe shutdown methodology and system design.
 
21. A list of applicable codes and standards related to the design of plant fire protection features and evaluations of code deviations (i.e., a listing of the NFPA code editions committed to (Code of Record)).
22. The three most recent fire protection QA audits and/or fire protection self-assessments.
 
23. A list of open and closed fire protection problem identification and resolution reports [also known as action reports/condition reports/problem reports/problem investigation reports/
NCRs/EARs] associated with fire protection or Appendix R safe shutdown for the past three years.
 
24. A list of plant fire protection licensing basis documents (i.e., a list of the SERs and change evaluations which form the licensing basis for the facilitys post-fire safe shutdown configuration).
 
25. A list of fire protection or Appendix R calculations.
 
26. A list of fire impairments identified during the previous year.
 
27. A list of abbreviations/designators for plant systems.
}}
}}

Revision as of 04:25, 24 March 2020

IR 05000250-04-007, 05000251-04-007, on 01/26-30/04 and 02/09-13/04, Inspection Summary - Triennial Fire Protection Inspection at Turkey Point Nuclear Plant
ML050380365
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 02/17/2004
From: Fillion P, Payne D, Wiseman G
Division of Reactor Safety II
To:
References
FOIA/PA-2004-0277 IR-04-007
Download: ML050380365 (3)
v • d • e


Text

February 17, 2004 INSPECTION SUMMARY - TRIENNIAL FIRE PROTECTION INSPECTION AT TURKEY POINT NUCLEAR PLANT Report Number: 50-250, 251/2004007 Onsite Inspection Dates: 1/26-30/04 and 2/9-13/04 Inspection Team: Charlie Payne (team lead, operations); Gerry Wiseman (fire protection); Paul Fillion (electrical)

Accompanying Personnel: Kathleen O'Donohue, Team Leader; Necota Staples (electrical-training); Esperanza Espana, Visiting Inspector (Spain)

Scope: Routine Triennial Fire Protection Inspection, per IP 71111.05, focusing on selected fire areas/zones listed below. Selected fire areas included: Fire Zone 63 (Fire Area T) - Unit 3 Rod Control Equipment/3B MCC Room, +18 f level. Fire barriers in this area consist of 3-hour rated fire walls, the floor and the ceilin Fire detection includes ionization smoke detectors. Manual suppression is provided by the fire brigade. A severe fire in this area would involve a shutdown of Unit 3 from the main control room. Fire Zone 67 (Fire Area U) - Unit 4 Train B 4160V Switchgear Room, +18 ft. leve Fire barriers in this area consist of 3-hour rated fire walls, the floor and the ceiling. Fire detection includes ionization smoke detectors. Manual suppression is provided by the fire brigade. A severe fire in this area would involve a shutdown of Unit 4 from the main control room. Fire Zones 106 and 106R (Fire Area MM) - Unit 3 and Unit 4 Main Control Room, +42 ft. level. Fire barriers in this area consist of 3-hour rated fire walls, the floor and the ceiling. Fire detection includes ionization smoke detectors. This is a normally occupied space with manual suppression initially provided by the control room operators and later by the fire brigade. A severe fire in this area would involve a shutdown of both Unit 3 and Unit 4 from the main control room.

There were six inspection findings and five other issues identified.

FINDINGS 1) Failure to periodically test the auto start feature (on loss of power) for the TD fire pump.

2) Height of the curbs for some oil-retention basins are not sufficient to contain the entire contents of storage tanks.

3) Failure to identify that the RWST suction valve (LCV-3/4-11 5B) was subject to spurious operation. Applies to both FZ 63 and FZ 6 ) Failure to prevent spurious operation of thermal barrier cooling suction valve (MOV-4-626). Applies to FZ 67. (Licensee identified, but failed to take timely corrective action)

5) Failure to maintain adequate fire detector capability to ensure fire detection at the incipient stage. Applies to FZ 6 ) Local manual operator action to prevent spurious operation of a thermal barrier cooling water containment isolation valve (MOV-3/4-71 6A) was not timely to preclude RCP seal package damage. Applies to FZ 106.

7) Failure to install detection and fixed suppression in FZ 97. Part of the MCR envelop OTHER ISSUES 1) Assured operator access through security doors to various rooms and compartments during performance of local manual operator actions.

2) Assured operator access through specific locked security doors (no key card access available) during MCR evacuation local manual operator actions.

3) Unapproved local manual operator actions that were found to be feasible. (Licensee identified)

4) Procedure guidance allowing 20 minutes to complete local manual operator actions to restore RCP seal package cooling rather than 13 minutes as specified for similar condition during SBO events. (Licensee identified, but failed to take timely corrective action)

Inspection Successes:

1) Continue to experience a good synergistic working relationship between inspectors.

2) Developed new line of inquiry regarding operator access controls during fires.

Inspection Challenges:

1) Understanding the licensing basis in fire protection still continues to be problemati Licensee is arguing that the are only committed to select sections of NFPA codes but have no record as to which sections they are.

2) Scope of inspection is greater than inspection resources. Reducing sample size (included in new revision to IP 71111.05) will assure thorough review of area(s) selected.

3) The licensee is committed to using the EOPs as overall operating guidance during response to fire. Fire response procedures are lower tier documents (off-normal procedures) used as guidance only. Where conflicts between these procedures occur, the EOPs would have priority - despite the need to take some actions to protect safe

.

shutdown at the cost of reducing normal redundancy and reliability of ECCS equipmen This leaves the licensee vulnerable to actions contrary to SSD analysis and places high reliance on operator training and decision-making. The team found no basis to refute the licensee's approach but noted it was contrary to nearly all the rest of the industr ) The licensee's Ignition Source Data Sheets (ISDS) from the IPEEE contain skimpy information and are not adequate to support an SDP analysis in the fire protection are The licensee's risk analyst was aware of this and stated improvement plans would be implemented, within budget constraint Suggested areas of routine inspection focus:

Consider effects of room and compartment access controls when evaluating an operator's ability to successfully perform local manual operator action

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